Generally speaking, loans and partial surrenders from MECs result
in immediate taxation to the extent that the cash value of the contract exceeds the premiums paid.
However, there are exceptions, including: the
taxation of perquisites; where the employer uses the money to give a benefit
in kind which is not earnings or emoluments; and an arrangement by which the employer's payment does not give the intended recipient an
immediate vested beneficial interest but only a contingent interest.